While all Performance Standards are applicable to this investment, IFCs environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards. If IFCs investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
PS 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

This Project has been classified as Category B according to IFC’s E&S Sustainability Policy. The Project’s principal E&S risks and impacts will be associated with incremental pork and poultry production activities in Ecuador and the possible cross-border acquisition of an existing operation. Key E&S risks and impacts are likely to be similar to those in the Company’s existing operations, including, for example: management of solid and liquid wastes; effluents and emissions; occupational health and safety; human resource policy and working conditions of employees; and supply chain management for poultry and corn. These risks and impacts can be readily addressed through well established mitigation measures. Pronaca has shown a very high commitment to the management of environmental and social aspects of its operations since IFC’s initial environmental due diligence of the Company in 2004. Since that time, the Company has carried out substantial investments in reduction of effluents and wastes across its pork and poultry production and processing operations.

IFC's appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFCs requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through the implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives.

Policy



Environmental and social responsibility is embedded in Pronaca’s core corporate values which are centered in the principles of Integrity, Responsibility and Solidarity. These principles include aspects related to:

Providing innovative, healthy and quality food products for its consumers and contributing to the well-being and satisfaction of families.

Serving as a role model to its employees, by using effective, fair and ethical practices in the workplace and with service providers.

Applying a corporate responsibility philosophy to establish the best relationship within the community.

Treating providers with respect and fairness in every business transaction.

Using socially responsible practices with all its partners.



Identification of Risks and Impacts



Many of the Company’s operations pre-date the enactment of environmental licensing regulations. The Company has been making efforts, as early as 2005, to ensure compliance with licensing requirements, engaging with regulatory agencies and seeking the advice of specialized external legal counsel to understand and respond to its legal obligations. Based on information provided by the Company, current environmental licensing requirements applicable to facilities in existence prior to 2003 mainly apply to pig farms and industrial operations such as slaughtering and processing facilities as well as to some of the largest poultry farms. The applicability is based on the regulator’s review of a license application (“Ficha Ambiental”), which is reviewed by the competent regulatory agency who defines whether the facility must follow a more detailed Ex-post Environmental and Social Impact Assessment (E-ESIAs) study and the preparation of an Environmental Management Plan (EMP), following a pre-approved Terms of Reference (ToRs). Other facilities considered by the local regulators to represent a lower environmental risk are required to only complete the Ficha Ambiental complemented by a project-specific EMP.



Commercial and industrial activities situated in the Quito Metropolitan District are governed by a separate, alternate, licensing regime, allowed by the federal authorities as it is considered stricter. Under this regime, companies are required to apply for an Environmental Certificate which essentially entails the preparation of ESIA and EMP based on an audit of existing operations. In Quito, the management and corrective actions outlined in the EMP are legally binding obligations closely monitored and audited by the regulators.



In support of formalization of the environmental licensing status of its facilities, the Company has completed the required audits or ex-post Environmental & Social Impact Assessments (EIAs) and has submitted them to the regulators for review. The Company is not subject to fines or other regulatory actions, and the regulators are informed about the licensing status of all facilities. This has been done based on guidance from local environment
al counsel and in consultation with local authorities. The regulators (Ministry of Environment) are informed about the licensing status of all facilities.



The Ex-post Environmental and Social Impact Assessment (E-ESIAs) studies have been conducted by qualified external consultants for all of the Company’s existing facilities developments. The E-ESIAs cover operational phase impacts covering aspects, such as: air quality (emissions), water quality (effluents), wastes, flora, fauna, resource consumption, noise, etc.



The Company’s ESHS department participates in the due diligence of new land acquisitions to help identify and avoid environmental and social risks associated with Company expansion activities. Additionally, since 2005 the Company incorporates ESHS aspects into the design and construction of new facilities, learning from past experience about the need to, for example, reduce or eliminate wastewater streams for livestock farming and processing facilities.



Going forward, as set forth in the ESAP, the Company will contract the services of a qualified external consultant familiar with the IFC Performance Standards to perform an environmental, health, safety, and social (EHSS) audit of the proposed cross-border investment against IFC Performance Standards. If any gaps are identified as a result of the due diligence audit, the Company will address them according to a schedule mutually agreed between Pronaca and IFC. Additionally, for any new greenfield expansions in Ecuador or elsewhere, Pronaca will develop a complementary annex for EIAs to address any aspects from the IFC PSs not covered by local regulation. If any gaps are identified, the Company will address them according to a schedule mutually agreed between Pronaca and IFC.



Management Programs



The Company’s environmental and social management program includes a review of the environmental assessment documents, contracting and supervision of consultants to assist in the preparation and monitoring of environmental and social management plans, and a detailed series of environmental and occupational health and safety (OHS) management procedures. Environmental procedures include wastewater minimization and management; waste management; and emissions management among others. As previously mentioned, local environmental licensing processes include the development of facility-specific Environmental Management Plans (EMPs) which in Ecuador contain legally binding obligations to prevent and mitigate project-specific environmental impacts. Complementary actions required to comply with IFC requirements are described in the respective thematic sections described below.



Organizational Capacity and Competency



Responsibility for the management of environmental, social, health, safety (ESHS) and labor aspects is first centralized at the corporate level under the (Director) of social responsibility. Reporting to this Director is a corporate ESHS Department comprised of three
highly experienced and qualified managers who are respectively responsible for environment, occupational health and safety, and social programs. The Environmental Management Team has three regional coordinators which report to the Environmental Manager. Each of these coordinators is responsible for oversight of the environmental performance of facilities located in each of the main Company regions (Pacific Coast, Central Region, Mountain Region and Quito Metropolitan Area. The Occupational Health and Safety (OHS) Team is organized in the same manner as the Environmental Team. Community engagement activities are managed by a Social Programs coordinator. All regional coordinators are selectively hired based on a combination of academic preparation and previous, applicable professional experience. Additionally, each of the manufacturing / processing facilities has a responsible EHS coordinator while livestock farming facilities assign EHS responsibilities to the local managers and operators. Local coordinators and/or operators are responsible for implementing EHS procedures and self-audits. The organizational structure of the ESHS department ensures that applicable corporate policies are implemented in an integrated manner.



The Company relies on the support of external technical services providers for the preparation of ESIAs and for the monitoring of effluents and emissions. Monitoring of other environmental aspects such as wastes (hazardous and non-hazardous), energy and water consumption and other environmental matters are the responsibility of the Operations and Maintenance Managers at the facility and corporate level.



For the management of environmental, OHS and social aspects of its operations at the corporate level, the Company hires trained and experienced professionals who as part of their respective units oversee consultants’ as described above. Consultants who assist with assessment and monitoring activities are also selected based on their qualifications and training.



At the operational level within its livestock raising and processing operations, the Company also hires specialized personnel (such as wastewater treatment plant operators) and further provides training to persons responsible for the implementation of OHS and environmental programs (such as those with supervisory responsibilities at the plant level). Workers must also go through induction and refresher training on health, safety, social and environmental aspects applicable to their job tasks.



Going forward, as set forth in the ESAP, the Company will extend the corporate EHSS management procedures currently applied in Ecuador to new cross-border acquisitions. This will include assignment of an adequate local EHSS management structure (i.e. environmental, health, safety, and social coordination) as well as implementing the internal auditing, monitoring, and reporting procedures currently applied to its operations in Ecuador.



Emergency Preparednes
s and Response (EPR)



In order to comply with Ecuadorian regulatory requirements, the Company is required to develop occupational health and safety plans and procedures applicable to is operations which include emergency preparedness and response. EPR plans include such aspects as coordination with external entities; use of EPR response equipment; emergency contacts; training; and response procedures.



Monitoring and Review



Key environmental, health, safety and social indicators applicable to the Company’s operations are monitored independently by the respective corporate teams responsible for environmental, OHS, and social programs. Environmental monitoring activities focus on the quality of effluents, air emissions and generation of solid non-hazardous wastes. An external consulting firm is hired to conduct comprehensive quarterly effluent monitoring for the following parameters: pH, biological oxygen demand (BOD), chemical oxygen demand (COD), oil & grease, total suspended solids, sulfides, fecal coliform, and surfactants. Additional information about effluent and emissions performance is described under the PS3 section of this summary.



The corporate ESHS management team conducts audits of all facilities based on an audit plan. These internal audits focus on the commitments of facilities with local regulators as defined in the Environmental Management Plans (EMPs). Facilities located in the Quito Region are further the subject of random regulator audits. Management actions outlined in facility-level EMPs are considered to be legally binding commitments with local regulators and are subject to fines in the event of non-compliance.



Occupational health and safety (OHS) monitoring activities also consist of an internal audit program of operations to observe adherence to OHS procedures, as well as monitoring on the frequency and severity of illnesses and accidents across all operations. Accident rates are reported up to the Company’s executive directors and senior management on a monthly basis. All other environmental aspects are included in a quarterly report to senior management. The report includes rates of compliance and non-compliance with regulatory requirements; risk rates; accident and morbidity rates; status of emergency training; etc.



The Company has also published its first annual sustainability report consistent with the Global Reporting Initiative (GRI) and the Global Compact covering the 2010 period (2011 Sustainability Report). The report includes a comprehensive review of key social and environmental indicators including, for example: employment generation in the Company’s value chain; occupational accident rates; energy and water consumption; hazardous and non-hazardous wastes; food safety certifications; and number of direct employees, among others.

Working Conditions and Management of Worker Relationship



The Sponsor has approximately 7,700 direct employees, of which approximately 65% are dedicated to operational activities with the remaining dedicated to administrative functions (i.e. project planning, accounting, human resources management, etc).



The Company currently communicates employee rights and responsibilities through an Internal Employment Rules Handbook and through employment contracts. The Internal Employment Rules Handbook defines Company policy regarding the start and termination of employment contracts; working hours; attendance requirements and control; overtime conditions and benefits; especial permits for absences; vacancies, replacements, and promotions; payment for work and vacations; employer responsibilities; employee responsibilities; and disciplinary rules. Individual employment contracts further define working hours and compensation applicable to the individual.



Worker’s Grievance Mechanism



The Company employees are currently able to lodge complaints internally through the Human Resources department and Company management. Going forward, as spelt out in the ESAP, the Company will amend the grievance process currently included in the Internal Employment Rules Handbook to ensure consistency with IFC’s Performance Standard 2 by allowing: (a) any employee grievance by individuals or groups (including anonymous complaints) to be presented verbally or in writing, without the risk of reprisals; documented and reviewed by Company management and subject to a timetable for formal response and resolution; (b) providing workers the opportunity to meet with management; and (c) an appeal mechanism. The Company will make the grievance procedure available to all existing employees (through the intranet or another means of reaching all employees) and to all new employees at the time of hire (as part of its Human Resource Policy or other document). The grievance mechanism will otherwise comply with IFC PS2 requirements.



Workers’ Organizations



Ecuador has ratified the ILO conventions on freedom of association and collective bargaining and Ecuadorian laws protect workers’ rights in this regard. The Company reports that despite the fact that they do not restrict workers’ rights in this respect, none of its employees belong to external unions. There is an Employee Association which represents the workers common interests and regularly meets with Company management. Going forward, as spelt out in the ESAP, the Company will ensure that the Internal Employment Rules Handbook explicitly mentions workers’ rights to associate freely in accordance with Ecuadorian law.



Protecting the Workforce



Ecuadorian labor laws prohibit discriminatory practices and define minimum of age of work. The Company complies with local requirements, supporting equal opportunity and non-discrimination in employment and requiring all prospective employees to demonstrate proof of age o
f 18 years or older. Employment contracts and the Company’s employment rules do not allow for circumstances that could be construed as forced labor. The Company prides itself in being an industry leader in the hiring of persons with disabilities having reached the hiring of a total of 275 persons with disabilities in 2011.



Occupational Health and Safety



The Company’s environmental and social management program includes a detailed series of occupational health and safety (OHS) management procedures. The OHS management program is documented in part through a pocket OHS manual that is made available to all employees across the organization and through procedures made available through the Company’s intranet. Induction training applicable to all employees includes numerous aspects related to OHS policy, internal employment rules, and benefits. Specific training requirements are further defined in the OHS policy which requires employees to undergo training on the following basic aspects, depending on applicability to their job tasks: risk identification; chemical hazards; fire prevention and emergencies; use and maintenance of PPE; lifting safety; and housekeeping practices. The OHS policy further requires training on the following specific areas, also depending on the hazards associated with specific job tasks: work in extreme temperatures; repetitive motion; accident investigation and analysis; lock-out-tag-out procedures; proper use of hand tools; work in heights; hot work permits; confined spaces; electrical safety; biological hazards; ammonia management; and boiler safety.



Yearly training plans from each company facility are prepared by plant management and presented to the corporate OHS team for approval. Facilities are required to maintain registries of the training courses, recording attendance and topics covered. Facilities are also required to maintain records of accident and incident rates and to report these to Company management on a monthly basis. Accident frequency rates at the corporate level are 7.51 per one million work-hours. These rates compare favorably with the rates over the preceding three (3) years which show a decreasing trend.



Workers Engaged by Third Parties



The Company’s poultry production is supported by approximately 90 dedicated third party growers. These producers receive the hatched chicks and the poultry feed from Pronaca and are responsible for the chickens’ growth until they are ready to be taken to the slaughter house. Delivery of chicks and harvesting of grown chickens is conducted by workers from Pronaca. The typical outgrowing operation consists of a small company each employing between 5 and 15 workers who are mainly responsible for cleaning and feeding activities. As part of the outgrower contracting process, the Company requires them to hold the appropriate labor certifications and licenses to demonstrate legal employee contracting practices. Pronaca also assists its dedicated su
ppliers to obtain their environmental licenses by helping standardize the approach to completion of the Ficha Ambiental complemented by a project-specific EMP.



The Company is among the most important purchasers of corn in Ecuador in order to support its animal feed production operations and animal raising activities. About 15% of the Company’s demand for corn is supported by imports while the rest is supported by the production from third party suppliers inside Ecuador. The Company supports a fund, administered by a 3rd party credit entity, to pre-finance corn production. This relationship with corn producers is aimed at financing seed purchases, guaranteeing the purchase of production, and providing technical assistance to improve productivity. The Company also provides storage silos to help reduce transport costs. The Company has agreements with approximately 300 dedicate corn suppliers with average production areas above 10 hectares and another approximate 160 small producers with average production areas below 10 hectares. The Company’s heart of palm and artichoke businesses also rely on approximately 200 and 150 dedicated third party producers.



The Company is presently developing a pilot program to identify and address the potential presence of child labor in its supply chain, in collaboration with UNICEF, the Ecuador Ministry of Labor, and other private sector companies. The pilot program aims to reach a group of approximately 300 small rural producers who rely on manual labor for the planting and harvesting of corn and who are most likely to have the presence of harmful child labor.



Going forward, as spelt out in the ESAP, the Company will evaluate the risk associated with the potential presence of harmful child labor in its supply chain, particularly among its pre-financed suppliers of corn over which the Company is expected to be able to exert leverage, and develop an action plan to address this issue if the presence of harmful child labor is confirmed. This will include development and implementation of a Supplier’s Code of Conduct to promote sustainable sourcing practices, promoting compliance with national labor and environmental laws and PS’s supply chain requirements., The evaluation will consists of an initial mapping exercise to identify the suppliers to be most likely engaging children in farm work to the detriment of their education, followed by an action plan and an on-going monitoring program, as required to address this issue if harmful child labor is identified in the initial survey. As part of the mapping exercise Pronaca will categorize suppliers and volumes according to identified E&S risks and impacts.

Solid Waste



The Company applies good international industry practice in the management of solid wastes generated in its facilities. Solid and liquid wastes in pig raising farms consist principally of pig manure and manure washwater. Several facilities treat this solid and liquid waste in bio-digesters which receive a mix of solid and liquid wastes generated from the cleaning of concrete lined pig pens. Solid residuals from the anaerobic treatment process are periodically removed for composting and use as soil amendment in local agricultural operations. The Company has also modified the pig raising operations of some farms to eliminate the use of water for cleaning purposes, thus eliminating the generation of effluents by adopting a new "deep bedding" system. Under the “deep-bedding” system, pigs are raised over a layer of rice husks which absorbs and composts all pig waste, eliminating effluents. The only solid waste generated is the composted material which is used as soil amendment by local farmers. Another added benefit of this system is that it dramatically reduces odorous emissions. Other sources of odorous emissions include the pig rearing facilities which make use of biodigesters and the rendering and wastewater treatment plants from pig and poultry processing. The Company respects properly setback requirements and strives to locate facilities in rural areas. The rendering and wastewater treatment facilities have odor emissions controls such as afterburners/flares.



Effluents



Wastewater discharges from existing pig raising facilities consist of treated effluents from the bio-digesters and treated wastewater from the poultry and pig processing facilities. Effluents from bio-digesters are being used for "fertigation" in the Company''s own palm heart plantations in some cases and at neighboring agricultural or cattle grazing areas in other cases. Wastewater treatment plants (WWTP) from the pig and poultry processing facilities include secondary treatment design to meet local standards and World Bank Group (WBG) effluent guidelines. The WWTP technology used in the Valle Hermoso and Bucay operations has been provided and installed by AQUA Industrial Water Treatment of the Netherlands. Pronaca monitors discharge water quality as well as upstream and downstream water quality in the receiving water body on a quarterly basis. In some cases, background water quality in the receiving water body is quite poor due to lack of public WWTPs for municipal sewage.



A review of wastewater discharge monitoring information for the Company’s operations in Ecuador shows that some facilities still have occasional non-conformances. Going forward, as spelt out in the ESAP, the Company will develop and implement action plans to address non-conformances of wastewater discharges from existing facilities in Ecuador (i.e. Inaexpo; Avepica; Faenadora Bucay; and Alimentos Quevedo).



Atmospheric Emissions, Including Greenhouse Gases (GHGs)

Potentia
l air emission sources from Pronaca facilities include diesel fueled boilers and generators which respectively provide steam or contingency power to Company facilities. Pronaca’s boilers and diesel generators are all below 50MWth installed capacity and some are even below 3MWth. Pronaca conducts semi-annual to annual emissions tests which indicate that the facilities’ emissions are generally below applicable WBG guideline values for particulate matter (PM), sulfur dioxide (SO2), and nitrogen oxides (NOx).



Sources of odorous emissions include the pig rearing facilities which make use of biodigesters and the rendering and wastewater treatment plants from pig and poultry processing. The Company respects properly setback requirements and does not install facilities near residential areas. The rendering and wastewater treatment facilities have odor emissions controls such as afterburners or flares. The deep bedding system used in some of the pig rearing facilities dramatically reduces odorous emissions at the source.





Energy Efficiency



Pronaca tracks energy consumption across all of its operations. The most significant sources of energy consumption include heating and cooling systems in pork and poultry processing (slaughterhouses) as well as in value-added food processing facilities, as well as cooling systems in pig and poultry farms, followed by facility lighting. Pronaca’s slaughtering and food processing facilities are modern installations that have incorporated energy efficiency aspects in its design and operation (i.e. insulation of heating and cooling system elements, compartmentalization, etc). Most of the pig and poultry farms use water-cooled tunneling systems and variable speed extraction fans.

Infrastructure and Equipment Design and Safety



Company facilities have controlled site access to avoid unauthorized entry into industrial facilities. Transportation activities for grains, poultry, pigs, and other company processes are conducted by third party contractors who are contractually required to have licensed drivers and properly registered vehicles. Where applicable, emergency response planning at production and processing facilities include elements of involvement and coordination with local community representatives and services although in most cases the worst-case scenarios do not represent risks of off-site impacts in the case of emergencies.



Community Health and Safety



The Company is committed to the production of high quality food products and thus requires its pig and poultry slaughtering as well as food processing facilities to maintain HACCP certification. It also has developed and implemented a state-of-the-art bio-security management program to prevent the introduction of Avian Influenza (AI) and Swine Flu (H1N1) diseases into its livestock or from its livestock to the external community.



The Company has additionally adopted animal welfare procedures that are consistent with internationally accepted practices, particularly in the pig and poultry raising facilities where animals are allowed to roam in common pens, and in slaughtering operations where the company has considered animal welfare in the process design, obtaining certification from international recognized experts from the United States. The Company is encouraged to continue to explore opportunities for improvements in animal welfare practices in the pig and poultry operations, including evaluation of training for animal handlers in production areas and review of current design of housing for breeding sows.



Security Personnel



Security personnel in the farms and manufacturing facilities are generally subcontracted or direct employees, unarmed, and trained to screen visitors for authorized access and to ensure that visitors follow the Company’s bio-security procedures. They are also trained to follow procedures in response to security threats which include contacting the local authorities.

Pronaca’s primary production and processing of pigs and poultry are conducted in confined facilities which do not require the use of extensive land resources and which are, as a matter of practice, developed in formerly established agricultural areas or areas destined for industrial use. However, Pronaca relies on an extensive network of dedicated third party suppliers for the production of palm hearts, artichoke, rice, and, most importantly, corn for the feed manufacturing facility.



The Company also has a fish processing business (Mr. Fish) which relies on the supply of wild catch mahi mahi and tuna fish to support a small production of frozen fish products. Mr. Fish represents less than 3% of the total frozen fish market in Ecuador and even less of the total fish processing industry.



Going forward, the Company will evaluate the risk for the potential for land conversion of natural and/or critical in its supply chain, particularly among its pre-financed suppliers of corn and other products, and develop an action plan to address this issue if the presence of potential conversion of natural and critical habitat is encountered. The evaluation will consists of an initial mapping exercise to identify the location of its suppliers with respect to legally protected areas or areas of potential biodiversity significance, followed by an action plan and an on-going monitoring program, as required to address this issue if necessary.

Client’s Community Engagement

As a customer service oriented organization providing important consumer products in Ecuador, the Company has substantial experience with external communications, including engagement with suppliers, customers and member of the local communities in which the Company operates. The Company has extensive social action programs which require constant communication with local communities including efforts through the company sponsored Fundacion San Luis (http://www.pronaca.com/site/principal.jsp?arb=175). This foundation focuses on the education and supplemental nutrition help to poor communities across Ecuador where Company’s operations are located.

Going forward and as part of the Company’s expansion activities, Pronaca will develop and implement a formal community engagement procedure applicable to expansion activities inside and outside of Ecuador. The procedure will define community engagement planning and implementation appropriate to the level of potential risk and impacts associated with the Company’s operations.

External Communications and Grievance Mechanisms

At the regional level in Ecuador, the Company has designated members of the social management team who are responsible for serving as the designated point of contact as part of the Company’s social programs. Going forward, the Company will develop and implement a formal, documented, process to manage community grievances. The process must document grievances received and responses provided (such as the name of the individual or organization; the date and nature of the complaint; any follow up actions taken; the final decision on the complaint; how and when relevant project decision was communicated to the complainant; and whether management action has been taken to avoid recurrence of community concerns in the future), and reported back to the affected communities periodically.

Maximiliano ProañoDirector de TesoreríaFabián HolguínGerente de TesoreríaPronaca SALos Naranjos N44-15 y Av. Los GranadosCasilla 17-17-1462Quito, Ecuador

Broad Community Support is not applicable for this project

PRONACA Agro – Environmental and Social Action Plan (ESAP)
PS1: Assessment and Management of Environmental and Social Risks and Impacts
Assessment of E&S Risks in New Cross-border Acquisitions Once an acquisition target has been identified, contract the services of a qualified external consultant familiar with the IFC Performance Standards to perform an environmental, health, safety, and social (EHSS) audit of the proposed cross-border investment against. If any gaps are identified as a result of the due diligence audit against applicable PS requirements, address them according to a schedule mutually agreed between Pronaca and IFC.	Prior to audit Within 30 days of audit completion Within 60 days of audit completion Based on mutually agreed schedule with IFC
E&S Assessment and Management Procedures • Develop standard ToR for complementary assessment of environmental and social impacts of new projects according to IFC Performance Standards. • Implementation of Corporate EHSS management procedures to new cross-border acquisitions. • Develop and implement a formal community engagement procedure applicable to expansion activities inside and outside of Ecuador according to IFC requirements. • Develop and implement a formal, documented, process to manage community grievances according to IFC requirements.	December 31, 2013
PS2: Labor and Working Conditions December 31, 2013
Human Resource (HR) Policies and Procedures • Amend the grievance process currently included in the Internal Employment Rules Handbook to ensure consistency with IFC’s Performance Standard 2. • Amend the Internal Employment Rules Handbook to explicitly mention workers’ rights to associate freely in accordance with Ecuadorian law.	March 31, 2014
Supply Chain • Evaluate the risk associated with the potential presence of harmful child labor in its supply chain (mapping exercise) and develop Corrective Action Plan (including Suppliers’ Code of Conduct) • Implement an action plan to address this issue if the presence of harmful child labor is confirmed.	December 31, 2013 Mutually agreed schedule with IFC
Action	Deadline
PS3: Resource Efficiency and Pollution Prevention
Effluents Develop and implement action plans to address non-conformances of wastewater discharges from existing facilities in Ecuador (i.e. Inaexpo; Avepica; Faenadora Bucay; and Alimentos Quevedo).	September 30, 2013 Mutually agreed schedule with IFC
PS6: Biodiversity Conservation and Natural Resources Management
Evaluate the risk of the potential for land conversion of Natural and/or Critical Habitat in supply chain, particularly among its pre-financed suppliers of corn and other products (mapping exercise). Develop and implement an action plan to address this issue if the presence of potential conversion of natural and critical habitat is encountered.	December 31, 2013 Mutually agreed schedule with IFC